+ All Categories
Home > Documents > An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel...

An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel...

Date post: 26-Feb-2021
Category:
Upload: others
View: 2 times
Download: 0 times
Share this document with a friend
82
An Audit Primer for Auditors of For-Profit Entities Receiving HHS Provider Relief Funds December 15, 2020 Governmental Audit Quality Center
Transcript
Page 1: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

An Audit Primer for Auditors of For-Profit Entities Receiving HHS Provider Relief Funds December 15, 2020

Governmental Audit Quality Center

Page 2: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Earning CPEDisable all pop-up blockers

Do not enlarge any windows as they can block you from seeing CPE markers

Any answer counts towards CPE credit

Earn credit by responding to 75% of pop-ups

Click the CPE button at the end of this webcast to claim your CPE certificate

If you viewed this webcast as a group, fill out the “Group Viewing Form” located in the same window

A post event e-mail with CPE information will be sent to you

2 Per NASBA, you cannot earn CPE credit by watching the archive of this webcast.

Page 3: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

More Helpful HintsAdjust your volume• Be sure your computer’s sound is turned on.• Click this button. Slide the control up or down to fit your needs.Ask your questions• Feel free to submit content related questions to the speaker by clicking

this button. • Someone is available to assist with your technology and CPE related

questions, as well. Download your materials• Access today’s slides and learning materials by clicking this download

button at any time during this presentation.• If you need help accessing these materials, send a message through the

Q&A application.Enable Closed Captioning• Enable Closed Captioning by clicking the “CC” box found at the bottom of

your screen.• If you are watching a rebroadcast, the CC button is located within the

Media Player.3

Page 4: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Today’s Speakers

Daron Tarlton,

CPA,Partner,

DHG

Mary Foelster,

CPA, AICPA

4

Amanda Ward,CPA,

Partner,Plante Moran

Page 5: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

What We Will Cover Today

5

Overview of COVID-19 Funding Including PRF

HHS Audit Requirements—For-Profit Entities

• Option 1 – Single Audit

• Option 2 – GAGAS Financial Audit

Challenge/Risk Areas and Uncertainties

A Primer on Government Auditing Standards

GAQC and Other AICPA Resources

Today’s focus is on for-profit entities subject to HHS audit requirements due to receipt of HHS awards

Page 6: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

What We Will Not Cover Today

6

Accounting requirements for PRF

NFP and governmental HC entity issues

Final answers on these for-profit audit engagements

• The GAQC will likely hold another Web event on this topic during first quarter 2021 once we have more clarity in certain areas

Looking for accounting guidance on PRF? Access AICPA TQAs on PRF at: https://www.aicpa.org/interestareas/frc/recentlyissuedtechnicalquestionsandanswers.html for non-governmental organizations and GASB Technical Bulletin 2020-1 at: www.gasb.org for governmental organizations.

Page 7: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Terminology and Abbreviations

7

Page 8: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

An Overview of COVID-19 Funding—Largest New Programs

Paycheck Protection Program(>$600B)

Federal Agency: SBAFor-profits, NFPs

Is not subject to single auditAssistance Listing: 59.073

Provider Relief Fund ($175B)

Federal Agency: HHSFor-Profits, NFPs, Governmental

EntitiesIs subject to single audit

Assistance Listing: 93.498

Coronavirus Relief Fund ($150B)

Federal Agency: TreasuryGovernmental Entities and Tribes

Is subject to single auditAssistance Listing: 21.019

Educational Stabilization Fund ($30.75B)

Federal Agency: EducationStates, Schools, IHE

Is subject to single auditAssistance Listing: 84.425

Applicable Laws

• Coronavirus Preparedness and Response Supplemental Appropriations Act

• Families First Coronavirus Response Act

• Coronavirus Aid, Relief, and Economic Security Act (CARES Act)

• Future relief funding?

8

Page 9: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

PRF Program

Page 10: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

What is PRF?

Provider relief funds were provided to hospitals and other healthcare providers, including those on the front lines of the coronavirus response

Funding supports healthcare-related expenses or lost revenue attributable to COVID-19 and ensures uninsured Americans can get treatment for COVID-19

10

Page 11: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

PRF—General DistributionPhase 1• $30 billion distributed on April 10 and April 17 to providers

that billed Medicare fee-for-service (Parts A or B) in 2019• $20 billion distributed beginning April 24 based on revenues

from CMS cost report data and submissions to the provider portal

Phase 2• $18 billion made available in June to Medicaid, CHIP,

dental providers and other providers who missed the Phase 1 distribution

Phase 3• $20 billion made available in October to Medicaid, CHIP,

dental, assisted living facilities, behavioral health and previously ineligible providers

11

Page 12: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

PRF—Targeted Distributions

12

• High Impact Area Relief• Rural• Rural Health Clinic• Skilled Nursing Facility• Nursing Home Infection Control• Indian Health Service• Safety Net Hospitals• Families First Coronavirus

Response Act

Page 13: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

PRF—HHS GuidanceCARES Act Provider Relief Fund: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html

CARES Act Provider Relief Fund General Information: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/general-information/index.html

CARES Act Provider Relief Fund: For Providers which includes copies of terms and conditions: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html

CARES Act Provider Relief Fund FAQs: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html

CARES Act Provider Relief Fund Reporting Requirements: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html

13

Guidance issued by HHS has been subject to change and has been updated/revised extensively over time.

Page 14: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Panel discussion – How much has the PRF and other for-profit HHS funding affected your practice?

14

Page 15: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

HHS Audit Requirements - For-Profit Entities

Page 16: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Panel discussion – What gives HHS its authority to require for-profit entities to have an audit of PRF funding?

16

Rules contained in 45 CFR Part 75, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards

Page 17: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

HHS For-Profit Audit Requirements45 CFR 75.216 & 75.501:

Commercial organizations that receive HHS awards of $750,000 or more have two options:

• Single or program-specific audit (single audit) in accordance with the 45 CFR 75 Subpart F

• Financial-related audit of all HHS awards in accordance with GAGAS

17

Page 18: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Commercial Organization Definition

Per 45 CFR Section 75.2, a commercial organization is defined as:

An organization, institution, corporation, or other legal entity, including, but not limited to, partnerships, sole proprietorships, and limited liability companies, that is organized or operated for the profit or benefit of its shareholders or other owners. The term includes small and large businesses and is used interchangeably with “for-profit organization.”

18

Page 19: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Types of For-Profit Entities Finding Themselves Subject to HHS Federal Audit Requirements

Hospitals Physician Groups

Assisted Living Facilities Dental Groups

Behavioral Health

Providers

Nursing Service and related providers

Hospice providers

Nursing and custodial care

facilities

Ambulatory health care

facilities

Eye and vision services providers

19

Page 20: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Which is it? Receipts or Expenditures of $750,000 or More?

History Intent?

20

The AICPA has a formal request into HHS asking for clarification on this point. Stay tuned!

Page 21: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS No Longer Refers to Financial-Related Audits

• Financial-related audits is outdated language

• Current GAGAS refers to these engagements as financial audits

• HHS regulations have not been updated

21

Financial-related Audits

Financial Audits

Page 22: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

What Assistance Listings are Subject to Audit?

• 93.498, Provider Relief Fund, General and Targeted Distribution

• 93.461, COVID-19 Testing for the Uninsured

• 93.697, COVID-19 Testing for Rural Health Clinics

However, if additional awards are received from HHS (for example, NIH Research and Development grants), remember that all HHS awards are subject to the audit.

22

Page 23: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Which Option is Preferable?

Single AuditFinancial audit in

accordance with GAGAS

23

Page 24: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Result of a Single AuditAuditee financial statements

• Auditor opinion on financial statements under GAAS and GAGAS

Auditee SEFA including all HHS awards

• Auditor in-relation-to reporting on SEFA

Auditor opinion on compliance and reporting on internal control over compliance under UG

• UG requires testing of internal control/low assessed level of control risk

Auditor Schedule of Findings and Questioned Costs

• Contents of this schedule defined in the UG24

Page 25: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Result of a GAGAS Financial Audit

Auditee Statement of Costs (including lost revenue)

Auditor issues an opinion on the statement

Auditor issues a report under GAGAS on compliance and internal control over financial reporting

If applicable, reporting/schedule of findings

25

Page 26: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Option 1—Single Audit

Page 27: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

There is more certainty with this option at this stage….why?

27

Auditors use the OMB Compliance Supplement to understand federal expectations for compliance requirements and suggested audit procedures for purposes of performing audit and forming an opinion on compliance

An addendum to the 2020 Compliance Supplement is expected any day

• Includes a section on PRF for auditors to use

• What will it say?

Once issued, you will be able to find the Addendum on the OMB Web site or broken down by section on the GAQC Web site at: https://www.aicpa.org/interestareas/governmentalauditquality/resources/singleaudit/2020-omb-compliance-supplement.html

Page 28: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Timing of SEFA Reporting—Single Audit OptionPRF expenditures and lost revenue will not be included on SEFAs until December 31, 2020, year-ends and laterThe Other Information section of the PRF section will provide specific requirements for SEFA reporting• It will link SEFA reporting for PRF to amounts

required to be reported directly to HHS at calendar year-end and again at June 30, 2021

28

Page 29: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

PRF SEFA single audit timing – a picture to help understanding!

29

Year end What is included on the SEFA?

How are amounts calculated? Other Information

Before 12/31/20 No PRF N/ARecipients will report the

2020 PRF expenditures and lost revenue in the 2021

audit

12/31/2020 2020 PRF expenditures and lost revenue

Based on 12/31/20 PRF reporting to HHS

After 12/31/20 but before 6/30/21

2020 PRF expenditures and lost revenue

Based on 12/31/20 PRF reporting to HHS

6/30/21 or after ? ? 2021 Supplement will provide guidance

Page 30: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

What do we expect in the Supplement Addendum for PRF? SUPPLEMENT MATRIX FOR PRF

30

For activities allowed and allowable costs the PRF Supplement will point auditors to the CARES Act provisions for PRF and the terms and conditions documents. HHS guidance document can be used to further understanding of those requirements.

Page 31: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

PRF reporting requirementSpecial reporting requirements for recipient reporting to HHS will be applicable only to audits of fiscal years ending on or after 12/31/20• Auditors will be expected to test this special reporting

requirement for 12/31/20 year ends even though reporting will not be able to be submitted by recipients until sometime in early 2021

At the time of issuance of the Addendum, the report and reporting portal are under development and not expected to be available by HHS before January 15, 2021• By February 1, 2021, a notice will be placed on OMB Web

site providing key line items and other information from the report that are subject to audit for audits of fiscal years ending on or after December 31, 2020

31

AICPA has expressed its concern to HHS about the timing of the issuance of the report and related guidance.

Page 32: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Other Expected Addendum Content

32

Assistance Listing 93.461 Supplement Matrix also included in the Addendum

A required footnote to the SEFA with the fair market value of donated PPE from a federal assistance source (can be marked unaudited)

Addendum also expected to provide for a 3-month audit submission extension for single audits of 2020 year-ends through September 30, 2020, year-ends only if the recipient received COVID-19 funding (e.g., June 30, 2020, single audits for such recipients will now be due June 30, 2021)

Page 33: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Expected Addendum extensions for 2020 single audits at a glance

33

SNAPSHOT OF IMPACT OF OMB ADDENDUM 3-MONTH AUDIT EXTENSION ON VARIOUS FISCAL YEAR-ENDS FOR ENTITIES RECEIVING COVID-19 FUNDING

Fiscal Year End Normal Due Date* Extended Due Date* (3-month extension)

January 31, 2020 October 31, 2020 January 31, 2021

February 29, 2020 November 30, 2020 February 28, 2021

March 31, 2020 December 31, 2020 March 31, 2021

April 30, 2020 January 31, 2021 April 30, 2021

May 31, 2020 February 28, 2021 May 31, 2021*

June 30, 2020 March 31, 2021 June 30, 2021

July 31, 2020 April 30, 2021 July 31, 2021August 31, 2020 May 31, 2021 August 31, 2021

September 30, 2020 June 30, 2021 September 30, 2021

*Per section 200.512 of the Uniform Guidance, if the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Dates in these columns have NOT been adjusted accordingly.

Page 34: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Option 2—GAGAS Financial Audit

Page 35: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

There is currently more uncertainty with this option at this stage….why?

35

HHS has not communicated its expectations in any level of detail yet on this option

AICPA has issued communication to HHS asking for clarification on:

• Receipts versus expenditures concept discussed earlier

• Framework for statement of costs (e.g., GAAP, special-purpose?)

• Will the required donated PPE footnote HHS is requiring for the SEFA in the single audit option be required for the statement of costs in the GAGAS financial audit option?

• Whether PRF SEFA timing related to expenditures and lost revenue would also translate over to the GAGAS financial audit option

• Whether audit deadlines extensions in single audit world extend over to the GAGAS financial audit option

Let’s talk more about what we do know about this option!

Page 36: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

This Option Will Likely Involve the Client Preparing a Financial Statement of HHS Awards—One Example

36Not a final illustration!

Page 37: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

This Option Will Likely Involve the Client Preparing a Financial Statement of HHS Awards—Another Example

37 Not a final illustration!

Page 38: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Financial Statement of HHS Awards—Potential NotesGeneral

• Entity description, funding received

Summary of Significant Accounting Policies

• Basis of Presentation

• Estimates

• Subsequent Events

Contingencies

• Grant programs being subject to review and audit by HHS

We’ve sent illustrative notes to HHS to review

along with the illustrative financial

statements. We’re still awaiting

feedback.

38

Page 39: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Applicable AICPA Auditing Standards

39

AU-C 805B, Special Considerations—Audits of Single Financial Statements and Specific Elements, Accounts, or Items of a Financial Statement

In an audit of a single financial statement, the auditor should adapt all AU-C sections relevant to the audit as necessary in the circumstances of the engagement

All relevant AU-C sections should be applied to the audit of the statement prepared by the client

Determine materiality for the single financial statement versus the complete set of financial statements

Page 40: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Compliance and Internal Control ConsiderationsWhile opinion on compliance not required, compliance still needs to be considered by the auditor• AU-C 205B, Consideration of Laws and Regulations

in an Audit of Financial Statements, requires consideration of noncompliance with laws and regulations that could result in material misstatements of the statement prepared by the client

• GAGAS extends beyond the AICPA requirements and requires the auditor to also consider noncompliance with the provisions of contracts and grant agreements

40

Normal responsibilities for internal controls for financial statement engagements apply

here also.

See AU-C 315, Understanding the

Entity and Its Environment and

Assessing the Risk of Material

Misstatement

Page 41: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Determining Material Provisions of Laws, Regulations, Contracts, and Grant Agreements for Compliance Purposes

41

Professional judgment is required. However, the auditor should consider the following information in making this determination:

• Terms and conditions of the HHS awards• HHS publicly posted information on the PRF and other HHS

programs (such as FAQs, which can be accessed here)• The 2020 Compliance Supplement and its related

addendum to gain understanding of which requirements HHS identified as subject to audit for relevant HHS programs (see matrices for PRF and COVID-19 Testing for the Uninsured)

Page 42: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Panel discussion – How are you going to address testing compliance under this GAGAS financial audit option?

42

Page 43: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Reports—GAGAS Financial Audit Option

Opinion on statement using AU-C 805B reporting guidance

GAGAS report on the scope and results of testing of the audited entity's internal control over financial reporting and compliance with laws, regulations, and provisions of contracts and grant agreements, and other matters (discussed in more detail in later section)

• Not opinion-level assurance43

Page 44: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Challenge/Risk Areas and Uncertainties

Page 45: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Uncertainty—GAGAS Financial Audits

Will certain areas clarified for PRF single audits be relevant to the GAGAS financial audits?

• These were discussed earlier but are still very important questions that need to be addressed by HHS

Guidance from HHS has been a moving target

45

Page 46: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Panel discussion – How have the continual changes in PRF guidance impacted your clients and your practice?

46

Page 47: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Uncertainty—Timing of HHS Reporting GuidanceWhen will HHS release its detailed reporting requirements? Recipients must report for calendar year 2020 and the six months ending June 30, 2021Will a Paperwork Reduction Act filing be required?• If so, a FR notice will be needed along with a

comment period which could delay thingsHow will requirements be issued timely??47

Page 48: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Implications of COVID-19 Funding on HC Industry for Both Audit OptionsMany new/first-time audits of for-profit HC entities over next two years• Stress on available firm resources• Consideration of unaudited baseline 2019 informationIncreased risk due to entities and auditors that may be unfamiliar with single audit/GAGAS requirementsIncreased risk due to federal agency guidance relating to new COVID-19 funding that continually has been updated/revisedTiming issues as the majority of the required for-profit audits have been on hold waiting for guidance

48

Page 49: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Challenge Area—Firm Resources

• Due to delays in audit guidance, work is being pushed into different periods causing a workload problem

• GAGAS competency considerations

49

Page 50: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Panel discussion – How has your firm been dealing with the risks around these new audit requirements, staff experience issues, and clients that are first-time auditees?

50

Page 51: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Challenge Area—Finding a Quality Auditor

Marketing opportunity for firms with GAGAS/single

audit expertise

Entities need to ensure their auditors are competent

51

Access GAQC “Find a Member” section of GAQC Web site to locate GAQC member firms

Page 52: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Challenge Area—Organization-wide Audit or Individual Entity Audits?

52

Common question is the level at which one would audit a for-profit entity under the HHS for-profit rules if there are multiple entities involved that are consolidated or are part of the reporting entity?This question is addressed in the Uniform Guidance and described in in paragraph 6.15 of the GAS-SA Guide:• Audit must cover the entire operations of the auditee, or, at the

option of the auditee, such audit must include a series of audits that cover an auditee's departments, agencies, and other organizational properly units that expended or otherwise administered federal awards during the audit period

Page 53: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Challenge Area—Determining Requirements

53

Memos

Guidance Documents

FAQs

Terms and ConditionsSupplemental Fact Sheets

Agency Adoption of OMB Memos Agency Web Sites

Page 54: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Risk Area—Documentation Is Always Key But Is Especially Important NowDecisions will have to be made based on judgment and unclear guidance

DOCUMENT, DOCUMENT, DOCUMENT!

• Support for decisions—specific facts and circumstances, compliance guidance in effect at the time, assumptions made

54

Page 55: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Panel discussion – How are you and your clients dealing with all the uncertainty?

55

Page 56: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

A Primer on Government Auditing Standards

Page 57: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS Understanding Required for Both Audit OptionsIn a single audit, the audit is performed under GAGAS (both the financial statement audit and the compliance audit)

GAGAS is also the framework for the financial audit option

Let’s spend some time learning the basics of GAGAS and areas of emphasis

57

Page 58: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

What are Government Auditing Standards?

GAO Standards

AICPAStandards

Access the

2018 Yellow Book

58

Page 59: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Additional GAGAS Requirements

Independence Competence and CPE Reporting

Ethics and Professional Judgment, Quality Control and Peer Review, Audit Documentation,

Planning, Noncompliance with Contracts and Grant Agreements

59

Page 60: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS—Independence

60

Required for any period of time that falls within the period covered

by the financial statement audit and period of professional

engagement

GAGAS establishes a conceptual framework that auditors use to:• Identify threats to independence• Evaluate threats• Apply safeguards to address threats

Requirements in addition to AICPA Conceptual Framework

Page 61: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Applying the Conceptual Framework

1 • Meet the general requirements

2• Determine nonaudit services are not

otherwise prohibited

3 • Identify threats to auditor’s independence

4• Evaluate the significance of threats

5 • Identify and apply safeguards

HURDLE TEST: YB 3.73: Auditors should determine that the audited entity has designated an individual who possesses suitable SKE and who understands the nonauditservices to be provided sufficiently to oversee them.

Page 62: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS Independence Considerations for Preparing Accounting Records and Financial Statements—3 Buckets

62

Preparing F/S in their entirety

• Determining or changing accounting records

• Authorizing or approving the entity’s transactions; and

• Preparing or making changes to source documents without management approval

Other nonaudit services described in YB 3.89 related to preparing accounting records and F/S (see next slide)

Significant threats

Create threats –evaluate and document

Independence impaired!

321

Page 63: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS—Competence & CPE

Assign auditors to perform the audit who, before beginning the work on the audit, collectively possess the competence needed to address the audit objectives and perform the work in accordance with GAGAS. Indicators of competence include:

Technical knowledge and skills in areas such as GAGAS, standards, regulations, techniques, tools, and guidance; andCompetence for assigned roles (e.g., supervisory auditor, partner).

63

Page 64: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS—Competence & CPE Cont.

64

Subject matter directly related to the government environment, government auditing, or the specific or unique environment in which the audited entity operates.

24 CPE Hours

Subject matter that directly enhances the auditors’ professional expertise to conduct audits

56 CPE hours

Auditors who plan, direct, perform procedures for, or report on engagements conducted in accordance with GAGAS should complete at least 80 hours of CPE in every 2-year period as follows:

Page 65: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS—CPE Timing

65

Must auditors have required GAGAS CPE by the beginning of the engagement?

Per Yellow Book, paragraph 4.02, the audit organization’s management must assign auditors to conduct the engagement who, before beginning work on the engagement, collectively possess the competence needed to address the engagement objectives and perform their work in accordance with GAGAS.

Page 66: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Panel discussion – What advice do you have for auditors whose for-profit clients may have received federal funding, but the auditors have no experience in doing GAGAS or single audits?

66

Page 67: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS—Reporting

67

Report on financial statement State compliance with GAGAS

Report on internal control over

financial reporting and on compliance and other matters

Compliance with provisions of laws, regulations, contracts, and grant agreements; and instances of fraud

Presenting findings in the

audit report

Findings may involve deficiencies in internal control; noncompliance with provisions of laws, regulations, contracts, and grant agreements; or instances of fraud.

Page 68: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS—Reporting Cont.

Obtaining and reporting the views of responsible officials

Confidential or sensitive information• Disclosures concerning omissions

• Evaluate whether omission could distort audit results

Distributing reports

68

Page 69: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS Reporting—Findings in the Audit Report

69

Generally presented in a Schedule of Findings and Responses—required elements include:

Criteria

• What should the auditor have seen?

Condition

• What did the auditor see?

Cause

• Why did the auditor see what was seen?

Effect or potential effect

• What is the result of what the auditor saw?

Page 70: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAGAS Reporting—Views of Responsible Officials

70

• Planned corrective action concerning findings, conclusions, and recommendations

• Written response is preferred• If received orally, summarize and

include in the audit report

Generally presented in

a Schedule of Findings and Responses

Page 71: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Additional GAGAS Resources

• Government Auditing Standards, 2018 Edition

• GAO Yellow Book Webpage

• AICPA Audit Guide, Government Auditing Standards and Single Audits

• GAQC Archived Yellow Book Web Events (no CPE)

71

Page 72: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAQC and Other Resources

Page 73: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

About the GAQC – www.aicpa.org/GAQC

73

Provides resources (e.g., alerts, web events, tools, etc.)

Current areas of emphasis

• Government Auditing Standards

• Single audits

• Preparing for study on single audit quality

Even if not a member, GAQC Web site provides useful information for both auditors and auditees

• For example, GAQC Auditee Resource Center

Page 74: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Where Can I Find More Guidance?

Upcoming GAQC FAQ under development for the for-profit audit requirements to include:

• Part I: HHS Audit Requirements• Part II: GAGAS Financial Audit Option• Appendix A: Illustrative Statements• Appendix B: Illustrative Auditors’ Reports• Appendix C: A Primer on GAGAS

74

Page 75: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

AICPA Audit Guide, Government Auditing Standards and Single Audits

Key resource for auditors; you should be using this Guide!

eBook now available and paperback due any day

Key changes:• Government Auditing Standards, 2018 Revision

• Addition of concepts introduced in 2019 Compliance Supplement: 6-requirement mandate, internal controls

• New SASs on reporting discussed in a new appendix

• Slight changes to Yellow Book reports

75

Order now at: http://www.aicpastore.com/

Page 76: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Get Familiar with AU-C 805

Special Considerations—Audits of Single Financial Statements and Specific Elements, Accounts, or Items of a Financial Statement

76

Page 77: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Recent no-CPE Archived GAQC Web Events

• 2020 OMB Supplement Addendum and the Latest COVID-19 Single Audit Implications (12/10/20)

• 2020 Supplement and COVID-19 Single Audit Implications (9/9/20)

• 2020 Compliance Supplement and Single Audit Update (6/30/20)

• Single Audit Fundamentals (a 4-part series) (8/26 – 8/27/20)

• Preparing for your First Single Audit: An Auditee Perspective (9/14/20)

• OMB Supplement Addendum and the Latest COVID-19 Single Audit Implications

77

Access all at:

https://www.aicpa.org/interestareas/governmentalauditquality/resources/single-audit-archived-

events.html

Page 78: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAQC Single Audit Fundamentals

78

If you have staff that need the basics, GAQC offering a 4-part session as follows:

Single Audit Fundamental Series. See specific dates and times below for rebroadcasts. Use this link to register for all 4 parts.

Part 1: What is a Single Audit? A Basic Background and Overview. December 17, 2020, from 11:00 AM – 1:00 PM. Use this link to register for Part 1 only.

Part 2: Major Program Determination. December 17, 2020, from 2:00 PM – 4:00 PM. Use this link to register for Part 2 only.

Part 3: Understanding and Testing Compliance Requirements and Internal Control over Compliance. December 18, from 11:00 AM – 1:00 PM. Use this link to register for Part 3 only.

Part 4: Overview of Sampling and Single Audit Reporting Requirements. December 18, 2020, from 2:00 PM – 4:00 PM. Use this link to register for Part 4 only.

Additional rebroadcast dates coming soon!

Page 79: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

HHS Resources

CARES Act Provider Relief Fund: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html

CARES Act Provider Relief Fund General Information: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/general-information/index.html

CARES Act Provider Relief Fund: For Providers which includes copies of terms and conditions: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html

CARES Act Provider Relief Fund FAQs: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html

CARES Act Provider Relief Fund Reporting Requirements: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html

79

Page 80: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

GAO Resources

• 2018 Yellow Book

• COVID-19 Alert on CPE Requirements for Auditors

• COVID-19: GAGAS Audit Alert

80

Page 81: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Panel discussion - What do you think is the most important takeaway from today’s Web event?

81

Page 82: An Audit Primer for Auditors of For-Profit Entities Receiving … · 2021. 1. 14. · Panel discussion –How much has the PRF and other for- ... before 6/30/21; 2020 PRF expenditures

Thank you

Copyright © 2020 American Institute of CPAs. All rights reserved.

Governmental Audit Quality Center


Recommended